Avis relatif à la vie privée
Nous (également désignés par « Nous », « Notre » ou « Nos ») nous engageons à protéger vos Données à caractère personnel et votre vie privée.
La présente Politique de confidentialité vise à vous informer de la manière dont nous collectons et conservons les informations que vous fournissez via le site web https://titrasomme.com (le Titrasomme).
Les principes suivants seront respectés :
We want you to make informed decisions about how your Personal Data is used and processed. We use various methods and procedures to provide clear, relevant information. If we determine that you need specific details, we will provide them at the appropriate time. We are also available to answer questions about our data practices, your account control settings, or any applicable service limitations.
1. Le périmètre?
This Policy explains the types of personal data that Titrasomme collects about individuals, and how that data is processed, shared with third parties, stored, and secured.
This Policy covers information relating to an identified or identifiable natural person. An identifiable natural person is someone who can be identified directly or through a combination of additional information that we hold or can access.
In this Policy, “processing” means any activity involving the collection or use of personal data. This includes organizing, managing, structuring, and storing personal data.
Our services are intended for a general audience and are not designed for persons under 18 years of age. We do not knowingly request or collect information from persons under 18 years of age, and we do not knowingly allow them to use our services. If we discover that we have collected information about a child, we will delete it as soon as reasonably possible.
2. Quelles données personnelles détenons-nous vous concernant ?
When you access our service or service channels, or visit our website, we collect Personal Data. In some cases, we may ask you to provide it to us. In others, we collect Personal Data by analyzing how you use our Services or service channels, or when third-party partners share your information with us.
3. You are not required to provide personal data to the company, and there are no consequences if you do not.
However, you are not required to provide us with personal data. In certain circumstances, choosing not to provide certain personal data may limit our ability to provide the services or prevent users from accessing the website.
4. What types of personal data may we collect? When you visit our website, we may collect the following personal data:
This includes information related to your online activity logs and traffic data (including your IP address, access date, and access time), the language you use, software crash logs, browser type, and information about the device you use to access the service. The information we collect is not considered personal data and cannot be used to identify you.
Personal data We receive from you: any personal data you choose to provide to Us when you connect, through Us, to a third-party online trading platform.
Personal data you provide directly to third-party platforms to facilitate trading: this information includes your full name, address, phone number, and email address.
5. Transparency and grounds for processing your personal data
The Company processes your Personal Data for the purposes described in this section, in line with transparent data management and security practices.
The Company uses Personal Data concerning you only when there is a clear and appropriate reason. The following explains when the Company may process your Personal Data:
- You have consented to our processing of your personal data for one or more purposes. This applies when you submit personal data through the Website so we can transfer it to a third-party trading platform.
- The Company or a third party may need to process data to pursue legitimate interests. For example, this may be necessary to improve Our Services or defend rights in legal proceedings.
- Le traitement est conforme à des normes de service claires.
Contact us by email for more details about how we process information and the measures we use to protect it.
Below is a summary of why we may use the information you provide, including for account, service, and security purposes involving Personal Data.
Portée, Transparence
1. At your request, we may collect your Personal Data and share it with third-party service providers to help you access digital trading services. We will do so only if you ask us to arrange it.
You have consented to the processing of your Personal Data for one or more purposes.
2. To respond to your requests, questions, or concerns, we may need Personal Data to address any question you may have about the Services.
Le traitement est nécessaire aux fins des intérêts légitimes poursuivis par la Société ou par un tiers.
3. Les données à caractère personnel sont traitées uniquement lorsque cela est nécessaire à la gestion du compte, à la sécurité de la plateforme et aux exigences de service clairement énoncées.
Processing is necessary to provide secure and reliable account services.
4. Pour améliorer nos Services. Nous pouvons utiliser les Données à caractère personnel à cette fin, notamment les rapports de plantage et de dysfonctionnement collectés dans le cadre des Services.
Processing is necessary for the purposes of the legitimate interests of the Company or a third party.
5. To prevent fraud and misuse of our services
Le traitement est nécessaire aux fins des intérêts légitimes de la Société ou d’un tiers.
6. To carry out and manage activities that support the operation of our Services. These may include back-office functions, business development, strategic decision-making, internal review processes, and related activities.
The processing is necessary for the purposes of the legitimate interests of the Company or a third party.
7. We conduct analyses, including statistical analyses, and use various analytical techniques, including statistical methods, to support decisions on different matters.
Le traitement est nécessaire aux fins des intérêts légitimes poursuivis par la Société ou par un tiers.
8.
To protect our assets, rights, and interests, as well as those of third parties, we have implemented processes to assert and defend legal claims
We may process Personal Data when necessary to protect our rights, interests, and assets, or those of third parties, in accordance with applicable agreements, terms, conditions, and policies.
Processing is necessary for the purposes of the Company’s or a third party’s legitimate interests.
6. Transfer of personal data to third parties
The Company may also share Personal Data with third-party companies that provide services to us, such as hosting and storage providers, IP address data services, and user experience analytics.
You may also ask us to transmit certain Personal Data about you to third-party trading platforms. In that case, we will provide those platforms with the Personal Data you have given us. The use of your Personal Data by these platforms is subject to their own privacy policies. Your Personal Data may be shared with multiple trading platforms.
The Company may share Personal Data with related entities or business partners. This may provide the Company with resources that help strengthen and improve the products and services offered to customers.
Where necessary to protect the rights or assets of third parties, the Company may apply appropriate account controls, security practices, and transparent data processing procedures.
We may also share Personal Data about you with potential investors, acquirers, or lenders of the Company or another group company when a relevant transaction is being considered. This may include the transfer or sale of assets belonging to the Company or another group company, or form part of any merger, restructuring, consolidation, or insolvency involving the Company or another group company.
7. Cookies and third-party services
Third-party services, such as companies that provide advertising on our website or analytics services, may be used. These companies may also use cookies or similar technologies.
Cookies are small text files placed on your device whenever you visit or access the website. Cookies collect information about your preferences and browsing habits to improve your user experience, remember your choices, and tailor products and services that may interest you. Cookies are also used for statistical and analytical purposes.
Some of the cookies we use are session cookies. They are temporarily downloaded to your device and remain there for a short period, until you close your browser. Other cookies are persistent. Persistent cookies remain on your device for a certain period after you close your browser. They help the Website recognize you as a returning user and allow you to return to and use the website more easily.
Cookie categories:
Nous pouvons les utiliser aux fins prévues:
1. Les cookies sont nécessaires au site
These cookies are necessary to access the features you have requested and to navigate our website. They are used to provide the information, products, and services you have requested from us.
They are also necessary to allow your device to download and stream data. This enables you to browse the website, use its features, and return to pages you have already viewed.
Cookies collect personal data, such as your username and the date of your last login, to confirm that you are logged in to the site. Session cookies are deleted when you close your web browser.
2. Cookies fonctionnels
Cookies help us recognize you each time you visit our site and remember your settings and preferences.
Les cookies collectent des données à caractère personnel, telles que votre nom d’utilisateur et la date de votre dernière connexion, afin de confirmer que vous êtes bien connecté au site. Les cookies de session sont supprimés à la fermeture de votre navigateur web.
3. Cookies de performance
We use cookies to collect statistical data on site performance and help improve it. They also allow us to analyze how our website is used.
Cookies store anonymous data that is not linked to an identified or identifiable natural person. Some are deleted when you close your browser, while others may remain stored on your device indefinitely.
Cookies are blocked or have been deleted
To block or delete cookies, you will need to change your browser settings. Below are links to help you do this in some of the most commonly used browsers.
- Firefox
- Microsoft Edge
- Google Chrome
- Safari
However, please note that some or all website functions and features may not work as intended if this occurs.
ONLINE TRACKING NOTICE
This service currently does not respond to Do Not Track signals.
8. Retention of your personal data
The Company will retain your Personal Data for as long as necessary to achieve the purposes for which it is processed, as described in this Policy, or for longer where necessary to ensure account controls, security practices, and service standards.
We will share your information with third-party trading platforms for 12 months. If you consent, we will continue sharing your data for an additional 12 months.
We regularly review the Personal Data we retain to ensure it remains necessary.
9. Transfers of personal data to a third country or an international organization
Your personal information may be transferred to other countries. This means that your personal data may be sent to a third country outside your country of residence, or to an international organization or jurisdiction. The Company takes appropriate measures to protect the Personal Data you provide and help ensure that data users can exercise their rights and access effective remedies.
These protections and safeguards are available to all individuals residing in the EEA (European Economic Area).
- Transfert vers un pays tiers ou une organisation internationale offrant des garanties appropriées pour les Données personnelles, assorties de pratiques de sécurité transparentes, de normes claires de traitement des données et de contrôles adéquats visant à protéger les informations pendant le transfert.
- The transfer is managed under a clear agreement between the relevant entities or public authorities, with transparent conditions, defined controls, and service standards.
- The transfer was carried out in accordance with established data protection clauses and security practices designed to support the responsible processing of personal data. We apply transparent data transfer procedures, documented controls, and service standards to help protect information during cross-border processing.
The Company may provide details on the security measures used to protect your Personal Data when transferred to third countries or international organizations. To request this information, please email info@titrasomme.com
10. Personal data security
We implement appropriate organizational and technical measures to protect Personal Data. These measures are designed to reduce the risk of accidental or unlawful destruction, loss, alteration, or unauthorized access.
However, we cannot guarantee or ensure that your Personal Data will remain secure or error-free at all times. We are not liable for immaterial, incidental, or consequential losses arising from the use or disclosure of Personal Data, including any disclosure caused by transmission errors, unauthorized access by third parties, or circumstances beyond our reasonable control.
In certain circumstances beyond our control, we may be required to share Personal Data about you with third parties, such as service providers or public authorities. When this occurs, we cannot control the security measures applied to your Personal Data by those third parties.
Personal Data cannot be transmitted over the Internet with absolute security. The Company cannot guarantee the security of Personal Data that you transmit to us online.
11. Hyperlinks to websites operated by third parties
Links to third-party websites and applications may be available on our website. These websites and applications are operated independently and are not controlled by the Company. We are not responsible for how they collect or process Personal Data, and this Policy does not apply to any activity carried out through them.
Before accessing or using a third-party website or application, we recommend reviewing its privacy policy and practices. We also suggest reviewing them carefully before providing any Personal Data.
12. Modifications de la présente Politique
When you visit third-party websites or applications, we recommend reading their privacy policies before deciding to access or use their services. We also suggest carefully considering whether to provide them with Personal Data.
13. Vos droits relatifs à vos données personnelles
You have the right to ask us to confirm whether Personal Data concerning you is collected, to correct any inaccuracies, and to erase Personal Data that We no longer need. You may also ask us to restrict certain types of processing of your personal information.
If you reside in the EEA, please consult this page:
These rights apply to information you provide and to other Personal Data concerning you. You may request to exercise your rights by sending an email to the address below.
Right of access
You may ask the Company to confirm whether your Personal Data is being processed. If so, you may request access to that Personal Data.
The Company will provide an electronic copy of the Personal Data currently being processed and may charge a reasonable fee for any additional copy. The information will be provided electronically if you request it in that format.
Your right of access to Personal Data must not adversely affect the rights and freedoms of others. If a request may adversely affect another person’s rights or freedoms, the Company may refuse to act on it or limit the information provided.
Right to rectification
You may ask the Company to correct inaccurate Personal Data. You may also ask that incomplete Personal Data concerning you be completed, taking into account the purpose for which it is processed.
Right to erasure
You may request erasure where: (a) the Personal Data is no longer necessary for the purpose for which it was collected or processed; (b) You withdraw your consent and there is no other legal basis for the processing; (c) You object, on grounds relating to your situation, to the processing of Personal Data based on legitimate interests pursued by Us or by a third party; (e) the Personal Data has been unlawfully processed; or (f) the Personal Data must be erased to comply with an applicable legal obligation.
This right does not apply where the processing is necessary: (a) to comply with a legal obligation requiring processing under European Union or Member State law; or (b) to establish, exercise, or defend legal claims.
Restriction of processing
If you have concerns about the accuracy of your Personal Data, you may ask the Company to restrict its processing while the information is verified.
Where you request restriction of processing, the Personal Data may generally only be stored, unless you give your consent, or where processing is necessary to establish, exercise, or defend legal claims, protect another person’s rights, or address an important matter of public interest within the European Union or a Member State.
Right to data portability
Where processing is automated and based on your consent or on a contract concluded with you, you may request the Personal Data you have provided to the Company in a structured, commonly used, machine-readable format.
You may also ask the Company to transmit your Personal Data directly to another controller where technically feasible. Exercising your right to data portability does not affect your right to erasure. Data portability must not adversely affect the rights or freedoms of others.
Right to object
You may object at any time, on grounds relating to your situation, to the use of Personal Data concerning you where the processing is based on legitimate interests pursued by the Company or by a third party. This includes profiling based on those interests. We may continue the processing where there are compelling legitimate grounds that override your rights, freedoms, and interests, or where the processing is necessary to establish, exercise, or defend legal claims.
For direct marketing, You may object at any time to the processing of Personal Data concerning you, including related profiling.
Right to withdraw consent
You may withdraw your consent at any time to Our processing of Personal Data concerning you. This will not affect the validity of processing carried out on the basis of your consent before its withdrawal.
You may lodge a complaint directly with Us using the contact details provided below.
We aim to address privacy concerns clearly and fairly, explain how your Personal Data has been used, and provide an appropriate response to questions raised about its processing.
In certain circumstances, European Union or Member State laws may limit the rights relating to your Personal Data described in this section 13.
We will provide the information requested under your rights in section 13 of this Agreement within one month of receiving your request. This period may be extended by up to two additional months where necessary, depending on the complexity and number of requests. Within one month of receiving your request, We will inform you of any extension and explain the reasons for it.
Unless otherwise provided in section 13, the information requested under your rights in section 13 will be provided free of charge. If a request is manifestly unfounded or excessive, in particular because requests are repeated, We may charge a reasonable fee to cover the administrative cost of providing the information or taking the requested action. We may also refuse to act on the request.
If the Company has reasonable doubts about the identity of the person making a request, it may request the additional information necessary to confirm that person’s identity.